UNITED STATES DISTRICT COURT
MIDDLE DISTRICT OF FLORIDA
JACKSONVILLE DIVISION

UNITED STATES OF AMERICA

vs

LORRAINE BROWN

EXCERPT:

LORRAINE BROWN,
the defendant herein , did knowingly and willfully combine, conspire, confederate
and agree with others to commit certain offenses, to wit:

a. execute and attempt to execute a scheme and artifice to
defraud, and to obtain money and property by means of material false and
fraudulent pretenses, representations, and promises, by utilizing the United
States mail and private and commercial interstate carriers, for the purpose of
executing such scheme and artifice, in violation of Title 18, United States Code,
Section 1341 ; and,

b. execute and attempt to execute a scheme and artifice to
defraud, and to obtain money and property by means of material false and
fraudulent pretenses, representations, and promises, by transmitting and causing
to be transmitted by means of wire communications in interstate and foreign
commerce, writings, signs, visual pictures, and sounds, for the purpose of
executing such scheme and artifice, in violation of Title 18, United States Code,
Section 1343.

Manner and Means of the Conspiracy and Scheme and Artifice

8. The manner and means by which Brown, co-conspirators, and
others sought to accomplish the purposes and objectives of the conspiracy
include, but are not limited to, the following :

a. Beginning in or about 2005, employees of DocX, at the
direction of Brown and others, began forging and falsifying signatures on the
mortgage-related documents that they had been hired to prepare and file with
property recorders’ offices throughout the United States.

b. Unbeknownst to DocX’s clients, the Authorized Signers were
instructed by Brown and other DocX employees to allow other, unauthorized,
DocX employees to sign, and to have the document notarized as if the actual
Authorized Singer had executed the document.

c. Brown also hired temporary workers to sign as Authorized
Signers. These temporary employees worked for much lower costs and without
the quality control represented by Brown to DocX’s cl ients. In fact, some of
these temporary workers were able to sign thousands of documents a day.
These mortgage-related documents were fraudulently notarized by DocX
employees even though the Authorized Signer did not actually sign the
document.

d. These unauthorized signing and notarization practices
allowed DocX, Brown, and others to generate greater profit and make more money.

e. After these false documents were signed and notarized,
DocX filed them through the mails or by electronic methods with local county
property records offices. Many of these documents, particularly mortgage
assignments and lost note or assignment affidavits, were later relied upon in
court proceedings, including property foreclosures and in federal bankruptcy
court. Brown knew that these property recorders, as well as those who received
the documents such as courts, title insurers, and homeowners, relied on these
documents as genuine.

f. Brown and others also took various steps to conceal their
actions from detection from clients, LPS corporate headquarters, law
enforcement authorities, and others.

[…]

9. Factual Basis

Defendant is pleading guilty because defendant is in fact guilty. The
defendant certifies that defendant does hereby admit that the facts set forth in the
attached “Factual Basis,” which is incorporated herein by reference, are true, and were
this case to go to trial, the United States would be able to prove those specific facts and
others beyond a reasonable doubt.

[…]

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